Nancy Bonifant

Nancy Bonifant

Reed Smith

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Latest Publications


Identification of Overpayments: A Win for DOJ Cautions 'Prosecutorial Discretion' in Enforcement of an 'Unforgiving Rule'

On August 3, 2015, the Southern District of New York issued the first judicial opinion interpreting the Affordable Care Act’s “60-Day Overpayment Rule” in a False Claims Act (“FCA”) case. In a clear win for the Department of...more

8/19/2015 - 60-Day Rule Affordable Care Act CMS DOJ False Claims Act (FCA) Hospitals Overpayment

An Apple a Day Keeps the OIG Away: Practical Guidelines for Structuring Physician Compensation Arrangements to Avoid Kickback...

On June 9, 2015, the Office of the Inspector General of the Department of Health and Human Services (OIG) released a fraud alert warning physicians to scrutinize carefully the conditions and terms of any medical director or...more

6/16/2015 - Anti-Kickback Statute CMS Director Compensation Health Care Providers OIG

The Sunshine Physician Payment Final Rule Overview and Analysis

On February 1, 2013, the Centers for Medicare & Medicaid Services (CMS) of the Department of Health and Human Services (HHS) released the long-awaited Final Rule (Rule) to implement the “Sunshine” provisions of the Affordable...more

3/6/2013 - Affordable Care Act CMS Healthcare HHS Manufacturers Medical Devices Pharmaceutical Industry Physicians Sunshine Act

The HITECH Final Rule: The New Privacy/Security Rules of the Road Have Finally Arrived

Since the 2009 enactment of the Health Information Technology for Economic and Clinical Health Act (the “Act” or “HITECH Act”), compliance efforts associated with the Health Insurance Portability and Accountability Act of...more

2/20/2013 - Business Associates Data Protection HIPAA HIPAA Omnibus Rule HITECH IFRS Medical Records Patient Privacy Rights PHI Subcontractors

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